shall file a return. Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.

(b) Form and contents of return

Any return required by subsection (a) shall be in such form and set forth such information as the Secretary shall by regulations prescribe.

(c) Time for filing return

Any return required by subsection (a) shall be filed on or before the 90th day (or on or before such later day as the Secretary may by regulations prescribe) after the day on which the United States person becomes liable to file such return.

(d) 10-percent interest

For purposes of subsection (a), a 10-percent interest in a partnership is an interest described in section
6038(e)(3)(C).

(e) Cross reference

For provisions relating to penalties for violations of this section, see sections
6679 and
7203.

1997—Subsec. (a). Pub. L. 105–34, § 1143(a)(1), inserted at end “Paragraphs (1) and (2) shall apply to any acquisition or disposition only if the United States person directly or indirectly holds at least a 10-percent interest in such partnership either before or after such acquisition or disposition, and paragraph (3) shall apply to any change only if the change is equivalent to at least a 10-percent interest in such partnership.”

Pub. L. 105–34, title XI, § 1143(c),Aug. 5, 1997, 111 Stat. 984, provided that: “The amendments made by this section [amending this section and section
6679 of this title] shall apply to transfers and changes after the date of the enactment of this Act [Aug. 5, 1997].”

Effective Date

Pub. L. 97–248, title IV, § 407(b),Sept. 3, 1982, 96 Stat. 671, provided that: “The amendments made by section
405 [enacting this section and amending section
6679 of this title] shall apply with respect to acquisitions or dispositions of, or substantial changes in, interests in foreign partnerships occurring after the date of the enactment of this Act [Sept. 3, 1982].”

Special Rule for Certain International Satellite Partnerships

For provision that this section is not applicable to certain international satellite partnerships, see section 406 ofPub. L. 97–248, set out as a note under section
6231 of this title.

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